I emailed the OHA and received this reply to my questions:
1.) If you grow for someone other than yourself at your address then you would need to use CTS.
2.) See OMMP Plant Limit PDF to determine your situation: http://www.oregon.gov/oha/PH/DISEASESCONDITIONS/CHRONICDISEASE/MEDICALMARIJUANAPROGRAM/Documents/Plant-Limit-Chart.pdf
Thank you,
OMMP Staff

The language of SB1057 and HB2198, as well as the memo from OHA, is ambiguous. I am wondering if anyone has spoken to the OHA and knows the answer to these 2 questions:
1) If I am a patient growing for myself (At a registered grow site), AND I am growing for a 2nd patient who doesn't live at my grow site, do I still qualify for the 12 and under plant exemption to reporting? Or is the exemption only available to patients growing at their own address for themselves?
2) If I remain in the current OHA tracking system using the Exemption clause, am I allowed to have the 12 immature plants per patient that are 24" or taller, as well as unlimited immature clones under 24" (as provided by HB2198)?

Hello PIF Members,
Please see the attached bulletin relating to the public comment period for new OMMP Administrative rules. I encourage PIF members to read the proposed rules on the Oregon Health Authority (OHA) web site and submit comments to the OHA before June 3rd.
Below are the 2 comments that I sent into the OHA regarding new Administrative rules, and if you share my concerns, please email your comments to the program at, mailto:publichealth.rules@state.or.us. I would especially like to see an inexpensive Processor license class added for patients & growers to make "safe, non-extract type" concentrates from their own plant material. Basically, a Micro-processor who doesn't make high-heat or high-pressure type extracts, and only works from their own material. I hope that if you share this opinion, you will also send in your comments to the OHA or attend one of the OHA rule making meetings listed in the bulletin.
-Psychokitty
My submitted comments follow:
Comments for 2016 OHA OMMP administrative rule making
Micro-processor license
#1 Concern: Small OMMP growers and patients will no longer be able to do safe extraction of excess trim and popcorn flower to create clean concentrates, such as "Bubble Hash" or "Dry Kief Hash". Requiring the use of a 3rd party processor decreases the value of the product by fifty percent or more, and is not cost effective for small growers. Additionally, most processors require a 5lb minimum to even start processing, or charge a rate of as much as $650 a pound to do processing. Finally, the $4000 cost to obtain a full processor license is too expensive for the small grower to absorb relative to the volume of material that they will process on an annual basis.
Recommendation: Create a micro-processor license that allows growers and patients to self-process the flower and trim from their own harvests, using the "safe" methods available for making concentrates. License cost should be affordable --$200--, and allow the micro-processor to transfer their excess concentrates to the dispensaries (with the same lab testing requirements as regular processor licensees).
Transfers to Dispensaries
#2 Concern: Batch testing and lab sealing of products will make it hard to take excess product to the dispensaries for sales. Many small growers only have a couple of pounds to sell at a time, and may end up visiting dozens of dispensaries before a sale and transfer is made. At each dispensary, the buyer will want to smell the product as well as test it's density, and maybe even look at it under a microscope. This is impossible if the product is in sealed bags.
Recommendation: Create a method that allows the dispensaries to open and reseal bags while allowing for the integrity of the batch to be maintained. Maybe have the dispensary add their signature to any bag they open and reseal.
Informational_Bulletin_2016_11_Reminder_of_rulemaking_and_public_comment.pdf

Yes Offdababa, I reuse my soil. I just til in some compost every once in a while, and have at it again! I just want to give a shoutout to the guys at Cured Green, who have been very helpful in guiding my through the process of selling to a dispensary. Hopefully, if my harvest turns out good, some of my flowers will end up in the jars of their fine establishment. A few updated pics of my current grow follow. The 4 Blue Snowdogs in one greenhouse have merged into one giant 10'x10'x7' mass of green. They should finish in early October. My other greenhouse of Rocket Chunk is well into flowering, with loads of large buds that are filling in fast. The Rocket Chunk should finish in early September...making it an excellent choice for anyone in the PNW who wants to do an uncovered outdoor grow next summer. The early finish makes it much less susceptible to the Powdery Mildew and the bud rot that can come with September rains.

I am in the Portland metro area. My greenhouse grow of OregonGreenSeed Rocket Chunk, which is an Indica dominant hybrid has been flowering for over a week. My other strain, Blue Snowdog, which is a 50/50 Indica/Sativa hybrid is not yet flowering, but I expect it to start any day now.

Hi MycoDan,
Thank you very much for your direct and thorough answers. You've provided me more information in that response then I've been able to find in countless hours of reading various forums around the Internet. It is encouraging to find out that you work with small growers and are interested in meeting them. I will Private Message you tomorrow, to see if you are available for a face-to-face meeting in the near future. I live in West Linn, but I work in downtown Portland everyday and getting up to NE Portland is not a burden on me. My patient might also be interested in meeting you, as she has over 20 years experience in the restaurant business, and she has an interest in producing edibles. I'm sure she'd like to meet you.
I am growing in raised beds using organically amended sandy loam. I use organic fertilizers- NatureSafe 8-2-4, Jobe's Organics, Alaska Fish Fertilizer, worm castings, and Azomite dust for added micronutrients. The only pesticide I use is a foilar spray of diluted Neem and Kelp weekly. I have read mixed messages on when to stop using Neem, but it seems like I should discontinue spraying by the 3rd or 4th week of flowering, so that there is no taste residue in the dried flowers.
Again, thank you for all the information! Your Dispensary will be the first one I bring my flowers to, and hopefully we can start a business relationship that is mutually beneficial.
Best regards,
Psychokitty

Hello all,
I am a new OMMP grower, and I have questions about how one goes about selling excess medicine to dispensaries. I'm hoping that some other growers or dispensary owners will give me some tips to get me moving in the right direction. Here are some of my questions:
1) Am I, as an OMMP grower, allowed to go into dispensaries and talk directly with the owners? Or are only patients allowed in? Does the patient I grow for need to sign an authorization slip or be with me? Do dispensaries usually prefer growers to come visit them face-to-face, or would they typically rather be contacted by email or by phone?
2) How do the dispensaries want to receive the medicine? Should it be tested by a lab first by the grower, or do the dispensaries want to handle all the testing? If the grower should do the testing first...then how do I do that...do I just call up any lab and arrange to drop-off all the medicine at once for testing? Does the lab then test it and send it back to me with the results?
3) I've read about dispensaries not being able to get banking services. Does that mean that I should expect everything to be a cash transaction? Do the dispensaries want the growers to give them invoices, and be licensed as Businesses? Or is it just a handshake and an exchange? Should I, as a grower, be setting up a web site to promote my medicine as a brand...is that something dispensaries are looking for to help them sell the medicine?
4) How difficult is it to sell to dispensaries? I've been told by one person that it's next to impossible, because the market is oversaturated. That just seems odd to me. I can understand wholesale prices dropping when the market is oversaturated. But it doesn't look to me like prices are anywhere near a rock bottom.
5) I am growing a couple of strains from OregonGreenSeed that aren't the common ones I see on Leafly menus. Will that make it harder to sell the medicine, or are dispensaries looking to have a wide variety of meds, not just the big name ones? Also, do dispensaries buy clones...or is that really not even something they are interested in?
Any tips and/or advice from those with experience is greatly appreciated. My plants are getting big and starting to flower, and my patient's needs are really small. I would like to recoup some of the costs I've incurred so far, and not just end-up with a pile of canna-compost at the end of the year! Thank you for sharing your insights and experiences!
A couple photos attached from my small greenhouses. One greenhouse is growing OregonGreenSeed's Blue Snowdog. The other is growing OregonGreenSeed's Rocket Chunk. I did not anticipate them getting so large and growing into each other like they have.